Copping Category C Landfill Cell
EPA Fact Sheet
The EPA acknowledges the significant community interest in the Copping Category C Landfill Cell
proposal and has prepared this fact sheet in response to queries arising from the community.
Environmental Standards
The EPA sets environmental standards for Tasmanian landfills (Landfill Sustainability Guide 2004). It
is worth noting that these standards have advanced considerably over the past decade. Category C
or ‘secure’ landfills represent the highest level of containment. No existing Tasmanian landfill cells
satisfy the current requirements for secure landfills.
The EPA also publishes standards for the level of contamination that may be present in wastes to be
disposed of in Tasmanian landfills. Information Bulletin 105: Classification and Management of
Contaminated Soil for Disposal defines the level of contamination that may be present in soil-like
waste disposed in a Category C landfill cell (commonly referred to as Level 3 waste). Prior to 2009
such materials were disposed at landfills in northern Tasmania. Up until this time, these sites had
been approved as meeting the standard of the day for that disposal.
Assessment
The proposed Category C cell at the Copping Landfill was assessed, using a well-established statutory
assessment process, against contemporary standards. It was assessed as acceptable by the EPA
Board subject to compliance with detailed conditions. The assessment report and environmental
permit conditions are available at: http://epa.tas.gov.au/regulation/southern-waste-solutionscategory-c-cell-copping-landfill.
The assessment process included open advertising of the proposal, letters to nearby landowners,
and consideration by the independent Board of the EPA which is comprised of representatives from
the government, private and community spheres. Persons who submitted representations on the
proposal also had a right of appeal against the decision. Subsequent to the assessment process the
proponent, Southern Waste Solutions, has commenced further consultation. The EPA encourages
proponents to engage with their communities. The EPA does not advocate for, or against specific
project proposals, but seeks to inform the community about the environmental impacts of
proposals.
Regulation
The EPA is Tasmania’s principal regulator of potentially polluting activities and waste. Its role is to
ensure activities do not have an unacceptable impact on the environment or the community. This is
achieved through compliance with State and national legislation, Codes of Practice, guidelines, the
application of Best Practice Environmental Management (BPEM), Accepted Modern Technology
(AMT) and adherence to the principles of continual improvement, which relates to the expectation
that standards can, will and should change over time.
The Act provides for the EPA to set and enforce conditions on Level 2 activities, being those
industrial and municipal activities with the highest potential for emitting pollutants. The Act, State
Policies and regulations made under it also require approvals from the EPA to transport, manage and
dispose of waste.
The Copping proposal
Water Pollution
The proposed cell design incorporates a leachate collection and containment system underlain by
multiple liner systems. Leachate arising from the cell will drain from the cell to leachate containment
ponds for evaporation, monitoring and treatment, if required.
The multiple liners include two High Density Polyethylene (HDPE) liners, a Geosynthetic Clay Liner
(GCL) and a 1 metre compacted clay liner at the base of the landfill that will be required to have a
minimum permeability of 1.0 x 10-9 m/sec. Each of these liners acts as an independent barrier and
each has its own unique characteristics. For example, the GCL layer incorporates swelling clays which
can self-seal ruptures. The landfill liner layers are designed to have a very long lifespan and are
protected by intervening layers.
It is important to note that the potential contaminant pathways are restricted by these engineered
barriers and the likelihood of leachate discharging into the local surface waters or groundwater
system is considered negligible.
An engineered cap will be constructed upon completion of the cell to prevent ingress of rainwater,
effectively entombing the waste.
The proposal exceeds the EPA’s requirements for secure landfills.
In the unlikely event of a compromise of the liner integrity, initially this would show up in the
‘witness sump’ which is to be installed between the multiple independent liner layers. The ‘witness
sump’ collects and allows monitoring of any leachate which traverses the first two liner layers. The
nature of response would depend on the extent and nature of the breach and any associated
threats/risks posed. The proposal states that the chemical signature of any leachate reporting to the
‘witness sump’ will enable targeted remedial works in the relevant section of the cell. In addition to
the engineered liners described above, the depth to groundwater beneath the proposed cell
provides additional natural attenuation. Any small quantity of leachate escaping from the cell must
traverse the underlying rock and clay to reach the groundwater. Pollutants tend to adsorb onto clays
thereby providing natural attenuation of the pollution.
Even in the worst imaginable circumstances a range of management responses would be available to
reduce the risk of impact. Measures include including leachate diversion works, active leachate
extraction, groundwater abstraction, and capping to prevent leachate formation.
The topography is such that the risk of flooding is very low and appropriate management measures
to further reduce that risk are required in the form of storm water management. In the very
unlikely event of flooding of the cell, the proponent would be presented with a management
challenge in terms of managing and evaporating an increased volume of leachate but that is what
will be required.
The EPA has concluded that the proposal presents a very low risk to surface waters and
groundwater.
Airborne pollution
The cell will not receive domestic or municipal waste and as such will not contain materials that
might become windblown litter.
The proponent is required to ensure that dust does not cause harm or nuisance. The permit
conditions also require waste to be covered at the end of each day of waste disposal.
The risk of dust causing harm to livestock or vegetation or organic certification on your property is
very low but if dust does prove to a be a problem and the operator does not remedy the situation
voluntarily and immediately then certainly report the issue to the EPA incident number and we will
deal with the matter.
Transportation
The EPA regulates the transport of controlled waste in Tasmania through a system of registrations.
Conditions of registration include spill response requirements.
The materials being transported to the Copping cell will present much less risk to the public and the
environment than many of the everyday commodities and products routinely transported in heavy
goods vehicles.
The waste materials destined for the Copping cell are not acutely toxic and, being solid, are generally
quite amenable to clean up.
Seismic risk
The geology at the existing Copping landfill site was studied in detail before construction, using
geophysical surveys to gain a detailed understanding of the structural geological setting.
Expert advice to the EPA is to the effect that seismic risk is very low. Fault lines in the area are stable
and probably relate to intrusion of doleritic material during the Jurassic period. The cell design is
unlikely to be affected by minor tremors that may be experienced in Tasmania from time to time.
In the unlikely event of a severe seismic event in southern Tasmania, rupture of vessels and pipelines
would be likely to result in considerable quantities of contaminated material requiring disposal to a
secure landfill.
Ongoing regulation
The EPA will have ongoing responsibility for environmental regulation of the Category C cell. The
permit conditions do not explicitly authorise wastes to be deposited in the cell (other than those
already received at the Copping landfill). As such, waste to be deposited in the Category C cell will
require specific approval from the Director, EPA. Criteria for soil-like wastes that may be disposed in
the cell are specified in Bulletin 105: Classification and Management of Contaminated Soil for
Disposal.
The regulation of material that will be received will include a combination of factors including
independent sampling of waste materials prior to transport, transportation by registered controlled
waste transporters, visual inspection by the landfill operator at point of disposal and ongoing regular
landfill inspections as part of the EPA Division’s compliance audit protocols.
Reactions between waste types will be prevented through a Waste Segregation Plan which must be
prepared and submitted to the Director prior to commencement of waste disposal in the
cell. Importantly Tasmania does not have the type of industry sectors that typically generate highly
reactive wastes.
The Copping landfill is currently subject to a program of monitoring of surface and groundwaters and
reporting of results to the EPA. This program will be further expanded to cover the Category C cell.
Rehabilitation and after-care
It is the responsibility of the owners of the Copping facility to ensure that post-closure care
arrangements are in place and this will be part of the site Decommissioning and Rehabilitation Plan.
The Landfill Sustainability Guide 2004 indicates that landfill after-care may continue for decades and
must continue until the Director approves cessation of after-care activities.
The operator or land owner will be required to undertake ongoing maintenance in accordance with
an approved plan. Experience of the site during its operation will assist in informing the
requirements of that plan but it will certainly require maintenance of the cell cap and
monitoring. The operation and ownership of the site by local government makes the ongoing site
maintenance issue less of a concern.
For further information on the regulatory framework and the EPA Division’s role in regulating
controlled waste please visit the EPA’s website link below:
http://epa.tas.gov.au/regulation/controlled-waste
Alex Schaap,
Director, EPA
Tuesday 18 September 2012